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"hard look" at the potential impacts of the proposed permit renewal and it may find itself in violation of the Federal Land Policy and Management Act as noted above. Additionally, in examining the alternatives for a proposed action, the BLM's consideratioti of environmental impacts must be more than a formality. Considering environmental costs means seriously considering alternatives in order to avoid such costs. Calvert Cliffs' Coordinating Comm., Inc. v. U.S. Atomic Energy Comm., 449 F.2d 1109, 1128 (D.C. Cir. 1971). The Tenth Circuit examined NEPA's alternatives requirement and agreed with other courts that "have interpreted NEPA to preclude agencies from defining the objectives of their actions in terms so unreasonably narrow that they can be accomplished by only one alternative (i.e. the applicant's proposed project}." Colorado Environmental Coalition v. Dombeck, 185 F.3d 1162, 1165 (10th Cir. 1999), at 1174 (citing Simmons v. United States Corps ofEng'rs, 120 F.3d 664, 669 (7th Cir. 1997)). In particulaz, federal agencies must examine alternatives to proposed actions that will avoid or minimize adverse effects on the environment. 40 C.F.R § 1500.2(e). Federal agencies must also examine alternative mitigation measures. Id. The requirement to consider less damaging alternatives helps agencies meet NEPA's primary purpose of promoting "efforts which will prevent or eliminate damage to the environment and biosphere..." 42 U.S.C. § 4321. These statutory and regulatory requirements are also affirmed in BLM policy: "BLM officials may not so narrow the scope of a planning/NEPA document as to exclude a reasonable range of alternatives to the proposed action..." USDI Instruction Memorandum No. 2001-075. 3. Colorado's Comprehensive Wildlife Conservation Strategy 2005 The first two principles of Colorado's Comprehensive Wildlife Conservation Strategy are to (1) encourage and support conservation actions that meet the needs of species of greatest conservation need; and (2) manage for healthy key habitats and ecosystems so that all species of greatest conservation need will benefit. Representatives from the BLM participated in the prepazation of this plan, and the Colorado Division of Wildlife states that "all parties should consider this guidance along with other information as they implement actions that follow established public participation protocols and legal requirements when preparing decision documents and project proposals." The BLM should take this Conservation Strategy seriously and support conservation actions that meet the needs of the at-risk species in the project area by implementing conservation strategies that benefit these species. 4. Soil Compaction from Vehicles Associated with the Project May Have Profound Effects on the Habitat of Listed and Sensitive Plants Soil compaction may result from vehicles associated with the proposed project. Soil compaction can cause numerous ill effects on plant species. Some of the adverse effects resulting from soil compaction include: Center for Native Ecosystems Page 9 of 24 Scoping Comments for the Proposed Red Cliff Coal Mine